Unlicensed White Space Device Operations in the Television Bands

May 4, 2020

Marlene Dortch, Secretary
Federal Communications Commission
445 12th Street SW
Washington, D.C. 20554

Re: ET Docket No. 20-36, Unlicensed White Space Device Operations in the Television Bands

Dear Secretary Dortch:

On behalf of Pennsylvania Farm Bureau, the state’s largest general farm organization, I write to encourage the Federal Communications Commission to adopt the Notice of Proposed Rulemaking to allow unlicensed TV white space to be utilized to provide broadband services in rural and underserved areas.

Farmers depend on broadband for the viability of their operations. Many of the latest yield maximizing farming techniques require wireless broadband connections for data collection and analysis performed both on the farm and in remote data centers. In addition, farmers depend on broadband to conduct everyday business activities from recordkeeping to training to point-of-sale transactions, and so much more. As technology continues to evolve, our farmers and agribusinesses will continue to integrate these advances into their operations, increasing the importance of accessible, affordable and reliable broadband.

In addition, rural communities need access to health care, government services, and educational and business opportunities. For these communities, access can only be realized through broadband services and sophisticated technologies that require high-speed connections. Affordable broadband service that enables rural Americans to tap into health care and education services, government agencies and new business opportunities is critical if we want to keep our rural communities strong.

In Pennsylvania, roughly 18 percent of rural Pennsylvanians lack access to internet service, or only have low-speed options. Research performed by Penn State, with funding from the Center for Rural Pennsylvania, found that median broadband speeds across most areas of the state do not meet the FCC’s criteria to qualify as broadband. In fact, research showed that there were no counties in Pennsylvania where at least 50 percent of the populace received broadband connectivity, however, FCC’s official broadband maps show 100 percent broadband availability across the state.

The current COVID-19 outbreak has only emphasized the critical need for a reliable broadband infrastructure. It is critical that the Commission embrace an all-of-the-above approach to expand broadband services in rural and unserved areas. TV white space technology provides an affordable new method to deploy broadband that wirelessly transmits broadband signals over TV white space frequencies. The ability of these frequencies to transmit at a higher power allows the devices to reach greater distances. Access to affordable broadband is essential to modern agriculture, the farmers who grow our food, and the quality of life for rural Americans.

We strongly support the Commission’s Proposed Rulemaking as it would reduce the digital divide and provide an affordable solution for farmers and rural communities to access broadband services.

Rick Ebert